On November 18,2025, the U. S. Office of the Comptroller of the Currency (OCC) issued a landmark decision with Interpretive Letter 1186, confirming that national banks are now permitted to hold cryptocurrencies as principal for the explicit purpose of paying blockchain network fees, commonly known as “gas fees. ” This directive marks a pivotal moment in the ongoing convergence of traditional banking and digital asset infrastructure, offering new clarity on what is permissible for regulated financial institutions navigating blockchain operations.
What Does OCC Interpretive Letter 1186 Authorize?
The OCC’s latest guidance provides a green light for national banks to maintain crypto assets on their balance sheets, but with well-defined boundaries. Specifically, banks may now:
- Hold sufficient cryptocurrency to pay required network fees (gas) when facilitating transactions on public blockchains
- Test and operate blockchain platforms, whether developed in-house or sourced from third parties, by using small amounts of digital assets for operational purposes
This new policy builds on earlier OCC guidance that allowed for crypto custody services and certain stablecoin activities. However, Interpretive Letter 1186 is narrower in scope: it does not open the door to speculative trading or broad investment in cryptocurrencies by banks. Instead, it recognizes that paying network fees is an activity “incidental to the business of banking”: akin to covering postage or transaction costs in legacy systems.
Why Are Network Fees So Important for Banks?
Every transaction on a public blockchain requires payment of a network fee, an incentive mechanism that secures decentralized ledgers and processes transfers. For banks seeking to offer crypto payment rails or settle tokenized assets, these fees are unavoidable operational costs. The OCC’s move acknowledges this reality and provides legal certainty so that banks can:
- Process client transactions involving digital assets without regulatory ambiguity
- Pilot new blockchain-based services, including tokenized deposits or real-time settlement solutions
- Ensure compliance and risk management, since all activities must be conducted in a safe and sound manner under existing banking laws
This regulatory clarity removes a key friction point that previously stifled innovation among U. S. financial institutions wary of running afoul of federal law.
The Fine Print: Scope and Limitations for Crypto Holdings
The authority granted by OCC Letter 1186 is not carte blanche for banks to amass large cryptocurrency reserves. Instead, it is tightly scoped:
- Banks may only hold sufficient amounts needed for network fee payments or platform testing, not for speculative purposes.
- Banks must adhere strictly to safety and soundness standards already embedded within federal banking regulations.
- The policy applies exclusively to activities that are otherwise permissible under current law, meaning all other crypto-related initiatives still require separate regulatory review.
This approach balances innovation with prudence, ensuring that risk exposures remain manageable while allowing institutions to modernize their payment infrastructure.
How This Fits into the Broader Regulatory Landscape
The OCC’s decision reflects an evolving attitude among U. S. regulators toward responsible adoption of digital asset technologies. It aligns with earlier moves permitting regulated stablecoin activity and custody solutions, incremental steps toward integrating blockchains into the core plumbing of American finance.
Banks interested in leveraging these new permissions should consult both internal compliance teams and external counsel before proceeding. As always, rigorous risk management remains paramount, a principle enshrined in every aspect of OCC guidance over the past several years.
As banks begin to operationalize these new allowances, the practical implications are significant. By holding small amounts of crypto for network fees, U. S. banks can now directly interact with public blockchains, streamlining settlement, supporting tokenized asset transfers, and enabling more efficient cross-border payments. This is not a hypothetical; it’s a foundational step toward digital asset integration in mainstream banking.
Impacts on Crypto Custody and Institutional Adoption
While the OCC’s guidance does not grant banks authority to broadly hold or invest in cryptocurrencies, it does reinforce the legitimacy of crypto custody services. Banks already offering custody for clients’ digital assets now have an added layer of regulatory clarity for operational holdings. This could encourage more institutions to enter the space, knowing they can safely manage the practical aspects of blockchain-based services without regulatory overhang.
For institutional clients, such as asset managers, fintechs, and corporates, this development lowers barriers to adoption. They can transact with confidence that their banking partners are operating within a clear legal framework when handling network fees or facilitating tokenized settlements.
Operationalizing Blockchain Compliance in Banking
Implementing these changes is not a trivial task. Banks must establish robust internal controls to track and account for all crypto held for network fees. This includes:
- Segregating operational crypto holdings from any client assets or speculative positions
- Maintaining detailed records of all transactions involving blockchain network fees
- Regularly reviewing risk exposure and compliance protocols, as required by federal oversight
Banks should also anticipate ongoing scrutiny from both internal auditors and regulators as these practices evolve. The OCC has made it clear that safety and soundness remain non-negotiable standards in any digital asset activity.
What’s Next? Evolution Toward Broader Digital Asset Services
The OCC’s Interpretive Letter 1186 is best understood as part of a gradual progression rather than a sweeping overhaul. It signals openness to blockchain innovation while preserving guardrails that protect both institutions and consumers from undue risk.
If early adopters demonstrate strong compliance and risk management, pressure may build for further regulatory updates, potentially paving the way for expanded crypto services down the line. For now, however, U. S. banks must operate within these defined boundaries while exploring new efficiencies in payments and settlement infrastructure.
The intersection of traditional finance and decentralized technology continues to evolve rapidly. For those looking to stay ahead of regulatory shifts or compare how different institutions are adapting their offerings, see our deep-dive guide on how U. S. banks can now hold crypto for blockchain network fees.
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